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andycfc86  
#1 Posted : 22 July 2021 11:15:44(UTC)
Rank: New forum user
andycfc86

Hi all,

I was wondering if I could get some advice. I think I maybe over complicating things but could you please clarify:

Within an 8 hour TWA will the user generally be safe to use the COSHH item as the SDS shows the calculated exposure limit (using that product within that time frame) or that using the product may generate above the limits set and sampling should be carried out to know that they are within the limits set?

Thanks

Roundtuit  
#2 Posted : 22 July 2021 11:51:27(UTC)
Rank: Super forum user
Roundtuit

A Workplace Exposure Limit is not a target to work towards "safe" only occurs in the absence of the hazard.

The limits are there for you to determine if the material being used is "in control" i.e. you are not exceeding the published value or "out of control" i.e. you need additional measures over and above what you were doing at time of determination to reduce exposure.

If you don't measure you don't know.

Your target should always be zero level of exposure ISFAIRP.

Substances can also have a STEL (15 minute exposure) that needs considering within the days activity.

thanks 2 users thanked Roundtuit for this useful post.
andycfc86 on 22/07/2021(UTC), andycfc86 on 22/07/2021(UTC)
Roundtuit  
#3 Posted : 22 July 2021 11:51:27(UTC)
Rank: Super forum user
Roundtuit

A Workplace Exposure Limit is not a target to work towards "safe" only occurs in the absence of the hazard.

The limits are there for you to determine if the material being used is "in control" i.e. you are not exceeding the published value or "out of control" i.e. you need additional measures over and above what you were doing at time of determination to reduce exposure.

If you don't measure you don't know.

Your target should always be zero level of exposure ISFAIRP.

Substances can also have a STEL (15 minute exposure) that needs considering within the days activity.

thanks 2 users thanked Roundtuit for this useful post.
andycfc86 on 22/07/2021(UTC), andycfc86 on 22/07/2021(UTC)
peter gotch  
#4 Posted : 22 July 2021 12:25:50(UTC)
Rank: Super forum user
peter gotch

Hi Andy

In addition to what Roundtuit has said you should never assume that if your within any occupational exposure limit that conditions are safe.

OELs are almost invariably set as a reaction to past negative impacts of exposure, and are established following consultation between various stakeholders, so are usually compromises - usually the employers look for higher limits and, usually, the trade unions want lower ones.

But they also reflect limits that are relatively safe for the majority of the workforce - you might have say people with pre-existing respiratory issues, for whom exposure to some airborne contaminant at the OEL may be far from safe.

Over the passage of occupational health and safety regulatory history in the UK, OELs are in the main a relatively new thing (years or decades rather than a century or more). 

Initially the HSE adopted most OELs from those set in America by the ACGIH - latterly UK OELs have been more influenced by Europe. In each case, the UK has generally lagged behind international thinking on occupational health risks.

....and it is VERY rare for an OEL in the UK to be amended to be less stringent. Usually as greater knowledge becomes available they either stay where they are or get reduced to require more stringent control.

When I started work as a health and safety professional the limit for exposure to asbestos was 2 fibres per millilitre. That limit has been progressively made more stringent over the years. We have far more detailed and extensive data on the effects of exposure to asbestos than the vast majority of workplace occupational health risks.

COSHH requires exposure to be reduced to the lowest level that is reasonably practicable whether or not there is an OEL.

We do have a reasonably sound idea that roughly 13,000 people in the UK die prematurely each year as a result of exposure to occupational health risks and that about 12,000 of those are from respiratory diseases. We don't have very good intelligence as to exactly what contaminants (or mixes of contaminants) many of those people have been exposed to.

thanks 1 user thanked peter gotch for this useful post.
andycfc86 on 22/07/2021(UTC)
andycfc86  
#5 Posted : 22 July 2021 13:43:26(UTC)
Rank: New forum user
andycfc86

Thanks for the responces guys.

I appreciate that we must do all we can to protect users and try to eliminate hazards where ever possible (risk analysis approach) including but not limited to; COSHH Assessment would be generated and controls implemented.

It was more a question to clarify it in my head: that what they say is the WEL, it is that their assumption of the sustances release over that TWA. 

Thanks again.    

Roundtuit  
#6 Posted : 22 July 2021 15:22:43(UTC)
Rank: Super forum user
Roundtuit

No, it is not how much the supplier thinks will be released over an 8 hour period.

The eight hours is a consideration of a typical working day (in reality it should be 7 + a bit when you take out breaks).

The value as Peter indicated is published by the regulator. 

Measurement of the substance is normally conducted over a shorter period.

Bricks & Concrete contain RCS which has a TWA of 0.1mg/m3

In normal use RCS does not get released from bricks or concrete

When someone dry works bricks or concrete then RCS can be released - the quantity needs to be measured, not as what comes away from a single hole or cut but as a total exposure of the employee over time.

This time defined measurement could calculate as less than TWA indicating suitable control or it could be far in excess meaning more controls are needed.

Those controls (as with HAV's or noise) could include limiting the amount of time someone is exposed to the hazard.

thanks 2 users thanked Roundtuit for this useful post.
andycfc86 on 23/07/2021(UTC), andycfc86 on 23/07/2021(UTC)
Roundtuit  
#7 Posted : 22 July 2021 15:22:43(UTC)
Rank: Super forum user
Roundtuit

No, it is not how much the supplier thinks will be released over an 8 hour period.

The eight hours is a consideration of a typical working day (in reality it should be 7 + a bit when you take out breaks).

The value as Peter indicated is published by the regulator. 

Measurement of the substance is normally conducted over a shorter period.

Bricks & Concrete contain RCS which has a TWA of 0.1mg/m3

In normal use RCS does not get released from bricks or concrete

When someone dry works bricks or concrete then RCS can be released - the quantity needs to be measured, not as what comes away from a single hole or cut but as a total exposure of the employee over time.

This time defined measurement could calculate as less than TWA indicating suitable control or it could be far in excess meaning more controls are needed.

Those controls (as with HAV's or noise) could include limiting the amount of time someone is exposed to the hazard.

thanks 2 users thanked Roundtuit for this useful post.
andycfc86 on 23/07/2021(UTC), andycfc86 on 23/07/2021(UTC)
Kate  
#8 Posted : 22 July 2021 16:37:08(UTC)
Rank: Super forum user
Kate

The exposure limit is in some respects like a speed limit.

The speed limit tells you a maximum speed you must not exceed, set by the relevant authority.  You are legally not allowed to go faster than this.

It is not the same as either

(a) The speed you should be at which may be much less than the limit, depending on driving conditions

or

(b) The speed that vehicles are believed to travel at in practice

In the same way, the exposure limit is the maximum exposure you must not exceed, set by the relevant authority (not the manufacturer).  You are legally not allowed to have a higher exposure than this.

It is not the same as either

(a) The exposure you should be at which may be much less than the limit, depending on what is reasonably practicable

or

(b) The exposure that is believed to occur in practice

So the exposure limit does not represent how much exposure the manufacturer or anyone else thinks is going to occur.  

There may however be some information on likely exposure in normal use in the "extended" safety data sheet (should you manage to obtain this) which contains assessments of exposure scenarios.

thanks 2 users thanked Kate for this useful post.
andycfc86 on 23/07/2021(UTC), Powell21173 on 21/09/2021(UTC)
descarte8  
#9 Posted : 02 August 2021 09:08:44(UTC)
Rank: Super forum user
descarte8

However a DNEL and an exposure scenario (which may also be present with the MSDS) should actually anticipate the maximum quantity that a user is likely to be exposed to and that the control measures which are described in that scenario should prevent the DNEL from being exceeded.

stevedm  
#10 Posted : 02 August 2021 10:07:16(UTC)
Rank: Super forum user
stevedm

DNEL = Derived No Effect Limit..yes it is sometimes published on SDS but can be calculated by Occupational Hygienist/ Toxicologist...in essence you can equate the DNEL to the OEL..

chris.packham  
#11 Posted : 02 August 2021 16:01:27(UTC)
Rank: Super forum user
chris.packham

Keep in mind that WELs are only relevant for inhalation exposure. It is possible to be below the WEL and still have skin exposure sufficient to initiate a health reaction.

“Air threshold limits are insufficient to prevent adverse health effects in the case of contact with substances with a high dermal absorption potential.” - Drexler H, Skin protection and percutaneous absorption of chemical hazards, Int. Arch Occup. Environ. Health (2003)

DNELs are ‘derived’ exposure levels and have no real meaning when it comes to skin exposure“. Indeed, the whole topic of DNELs can be confusing. Consider the following:

“REACH legal text also states that . . . it may be necessary to identify different DNELs for each relevant human population (e.g. workers, consumers and humans via the environment) and possibly for certain vulnerable sub-populations (e.g. children, pregnant women) and for different routes of exposure.” – UK WATCH committee, Nov. 2006

So which DNEL(s) would you apply in your circumstances?

When it comes to skin…

“However, there is no scientific method of measuring the results of the body’s exposure to risk through dermal contact. Consequently no dermal exposure standards have been set.” - from “Occupational skin diseases and dermal exposure in the European Union (EU-25):policy and practice overview - European Agency for Safety and Health at Work

 and

“A generally accepted method, which is able to predict the dermal absorption potential of a substance in humans, does not currently exist.” – Drexler H, Skin protection and percutaneous absorption of chemical hazards, Int Arch Occup Environ Health, 2003, 76

also

“Direct transdermal uptake from air is not routinely considered. Yet the studies outlined in the previous paragraph suggest that, for at least some indoor pollutants, direct dermal uptake from air may occur at rates that are comparable to or larger than inhalation uptake.” – Weschler CJ, Nazarofi WW, Dermal Uptake of Organic Vapors Commonly Found in Indoor Air, Environmental Science & Technology, 2014, 48, 1230-1237

Furthermore, there are several thousand chemicals that are recognised as skin sensitisers that have not been assigned either a WEL nor Hazard Statement, so will not appear as such on a safety data sheet. Indeed, they may be in the chemical you will be using but not appear on the safety data sheet at all.

stevedm  
#12 Posted : 09 August 2021 06:28:09(UTC)
Rank: Super forum user
stevedm

bit off topic and track of this thread...DNEL is required to be calculated for some but not all exposure patterns...Acute short term local effect cannot always be calculated, dermal in your example, so it may be approriate to calculate a Derived Minimum Effect Level (DMEL)...I could go into a log rant but it isn't really for here about how this does and doesn't work in all cases - we deal with development products worldwide that don't really have a lot of study information to base it on so sometimes it is a right wing view based on experience of similar drugs/exposure routes...we are talking what I would call step 2/3 assessments here step 1 being COSHH which is beyond the scope of this discussion

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